An update to our 10-year-old passport photo app for macOS was rejected under “Guideline 1.1.6 - Safety - Objectionable Content.”
We have neither changed any of the app's existing features nor added new ones. This update only included minor changes to the user interface and an update to the age rating questionnaire in App Store Connect.
This is the reason for rejection provided to us by the reviewer:
Guideline 1.1.6 - Safety - Objectionable Content
Issue Description
The app contains content or features that are misleading, intended to deceive users, or are otherwise fraudulent.
Specifically, the app provides services for editing photos for government documents.
Note that adding a disclaimer to the app description is not sufficient if the rest of the metadata and the app are misleading.
Next Steps
It would be appropriate to remove any content or features from the app that could be misleading or enable fraudulent activity before resubmitting for review.
We are having difficulty understanding how Guideline 1.1.6 applies to our app.
The app is simply a tool for creating passport photos. Users select their own portrait photo and manually position and crop it to the required photo dimensions. The app does not manipulate the content of the photo, change facial features, or alter a person's appearance.
The app has been available for approximately 10 years and is also used as a professional tool by photographers around the world to prepare and print passport and ID photos for their customers.
It does not edit passports, ID cards, visas, or any other government documents. The output is simply a portrait photo in the selected dimensions that can be saved or printed.
The country-specific presets provide the required photo dimensions as well as a visual mask for head size and positioning, based on publicly available specifications published by the relevant authorities in each country. These presets are used only to help the user manually align and crop the portrait photo according to those published requirements. They are not templates for government documents.
We have submitted an appeal, as we believe there may be a misunderstanding about what the app actually does.
Has anyone else encountered a rejection under Guideline 1.1.6 for a passport photo or similar photo-formatting app?
We would particularly appreciate any insight into the statement that providing services for “editing photos for government documents” falls under Guideline 1.1.6. Is there a specific App Review policy regarding passport photo apps that we may have overlooked?
For additional context, this particular app does not include background replacement or automatic cropping.
However, even if an app did offer such features, passport-style photos are not used exclusively for passports or government-issued identity documents. They can also be used for driver's licenses, student IDs, fishing licenses, membership cards, employee IDs, and many other purposes. For some of these use cases, background replacement may be perfectly acceptable.
Requirements also vary depending on the country, authority, and intended use of the photo. It would therefore seem reasonable for users to decide how to prepare their photos based on the requirements applicable to their particular use case.
We would be very interested to hear how other developers interpret this guideline and whether anyone has encountered a similar situation.
Any experiences or advice would be greatly appreciated.